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EDSO for Smart Grids

E.DSO

E.DSO represents leading European electricity distribution system operators to advance smart grid technologies and market regulation.

Lobbying Activity

E.DSO demands stable AI rules to drive energy investments

5 Nov 2025
Topic — This consultation explores leveraging digital technologies and artificial intelligence within the European energy sector.
Message — E.DSO requests regulatory frameworks that ensure investment recovery and avoid disproportionate compliance burdens from AI regulations. They advocate for a pragmatic approach to data spaces that prioritizes interoperability between national systems. Finally, they urge the use of existing sectoral safety frameworks instead of new, parallel regimes.123
Why — These changes would lower compliance costs and guarantee financial returns on expensive digital infrastructure investments.45
Impact — Non-European technology providers may face market barriers as E.DSO pushes for European sovereignty and standards.6
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Electricity grid operators urge dedicated funding in next MFF

29 Oct 2025
Topic — The European Commission seeks feedback on the performance and architecture of future budgets.
Message — E.DSO requests that the EU earmark dedicated funding for smart electricity grids in future budgets. They demand that grants translate into real investment incentives by removing regulatory and tax barriers. Furthermore, they argue smart grid projects should be eligible for all relevant priority categories.123
Why — Dedicated funding would reduce debt and de-risk expensive grid infrastructure projects.45
Impact — Consumers and businesses might face higher electricity bills without public financing.6
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Smart Grid Group E.DSO Urges Earmarked EU Budget Funding

29 Oct 2025
Topic — The consultation covers the post-2027 EU long-term budget and funding for competitiveness.
Message — The group requests a dedicated portion of EU funds for electricity distribution networks. They emphasize that grid upgrades are essential to prevent bottlenecks in the energy transition. They also demand that national regulators stop taxing or penalizing EU grants.123
Why — Earmarked grants and tax exemptions would lower the financial burden of modernization.45
Impact — Without this funding, consumers face higher energy bills to cover infrastructure costs.67
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E.DSO calls for increased funding to modernize electricity grids

29 Oct 2025
Topic — The consultation concerns the EU's next long-term budget and regional funding priorities.
Message — The group calls for dedicated funding earmarks for electricity distribution grids within regional partnership plans. They also request the removal of regulatory barriers like taxing grants to incentivize infrastructure investment.12
Why — These measures would lower financial risks and reduce debt exposure for system operators.34
Impact — Energy consumers and industrial users face higher bills if grid upgrades lack funding.56
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Meeting with Joachim Balke (Head of Unit Energy)

9 Sept 2025 · Ares(2025)7552502 Representatives of E.DSO presented main points of their reply to the open public consultation on the Grid Package and indicated main priorities for the distribution system operators.

E.DSO urges EU to fund climate-resilient power grids

4 Sept 2025
Topic — The consultation addresses an integrated framework for European climate resilience and risk management.
Message — E.DSO wants regulators to fully cover costs for protecting distribution networks. They also request standardized climate scenarios to guide future infrastructure investments.12
Why — The proposal ensures that grid operators maintain financial stability while upgrading infrastructure.3
Impact — Consumers could face higher energy bills if adaptation costs are recovered through tariffs.4
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Response to Targeted technical update of EU rules on measuring instruments

3 Mar 2025

E.DSO welcomes the Commissions proposal and recognises the need for a technical update to the MID that addresses modern smart metering and EV supply equipment. However, we believe the proposal could benefit from additional clarifications and more balanced transitional measures. E.DSO supports the option of remote data display but it is imperative that the definitions surrounding metrologically controlled data channels and the role of supplementary gateway devices are refined. Our experience shows that DSOs already operate robust, secure communication networks; imposing extra hardware requirements risks redundancy and unnecessary costs. Moreover, in Annex Va on EV supply equipment, measurement accuracy requirements for EVSE meters are less stringent to those applied to utility meters. As directive 2024/1711/EU on Electricity Market Design will permit usage-based billing, DSOs will need to manage the consistency of data between EVSE and utility metering. The differing requirements could result in processing challenges and customer complaints. Therefore, E.DSO advocates for ensuring metrological consistency. Additionally, the proposed wording lacks a strict definition of the transfer point for AC charging with a separate plug. Although it might be assumed to be the charging station socket, this is not explicitly stated and should be clearly defined. Furthermore, the text defines the voltage range for AC measuring installations as 0.9 Un to 1.1 Un (approximately 207-253V), we recommend that the Commission consider broadening this range extending the lower limit to at least 196V (or even lower) and potentially raising the upper limit to better reflect real-world operating conditions. In addition, regarding the transitional arrangements as outlined in Article 2 of the proposal, a shorter re-certification period for instruments already in service could lead to administrative burdens and operational disruptions. We advocate for a more flexible transition, allowing for gradual adaptation and ensuring that ongoing service provision is not compromised. Finally, we reject the proposed deletion of the voltage range for the test without load (0.8Un to 1.1Un) in Annex V, Chapter 5.4, to Directive 2014/32/EU. Under established standards (DIN EN 50470-3, Chapter 7.6 and EN IEC 62052-11:2021/A11:2022, 7.6. cf), when voltage is applied without any current flowing, the meter must not register energy at any voltage between 0.8Un and 1.1Un. If the test at 0.8Un is removed, normal operating conditions according to Chapter 2, Annex V apply (0.9Un to 1.1Un), creating inconsistencies with these standards. In addition to testing at 1.1Un, a test at 0.8Un is needed to ensure metrological accuracy and regulatory alignment. In summary, we support the updates overall objectives, provided that these clarifications and adaptations are incorporated, thereby striking a balance between promoting innovation and safeguarding reliable, cost-effective metering practices across the EU.
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Meeting with Wopke Hoekstra (Commissioner) and

12 Feb 2025 · Dialogue on the future of the automotive sector - Thematic Working Group on 'Clean Transition and Decarbonisation'

Meeting with Pierre Schellekens (Director Energy)

6 Feb 2025 · Exchange on the Commission’s upcoming initiatives, with focus on EU distribution grids

Meeting with András Gyürk (Member of the European Parliament, Shadow rapporteur)

17 Jan 2025 · Electricity grids

Meeting with Jutta Paulus (Member of the European Parliament) and Eurelectric aisbl and

15 Jan 2025 · Energy Breakfast

Meeting with Tsvetelina Penkova (Member of the European Parliament)

16 Sept 2024 · Future priorities

Meeting with Maroš Šefčovič (Executive Vice-President) and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Meeting with Ditte Juul-Joergensen (Director-General Energy) and EPIA SolarPower Europe and

26 Feb 2024 · Clean Transition Dialogue on EGD Infrastructures

Grid Operators Seek Investment Predictability and Metering Clarity

22 May 2023
Topic — EU consultation on reforming electricity market design for better resilience and decarbonization.
Message — EDSO requests stable regulatory frameworks and compensation models to support capital-intensive grid infrastructure investments. They also demand a clear distinction between regulated meters and third-party devices to maintain billing integrity.123
Why — This approach would protect their revenue models while reducing the technical burden of integrating uncertified devices.45
Impact — Third-party service providers could face restricted market access if excluded from official DSO billing and settlement processes.6
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Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

19 May 2023 · Meeting with EDSO on NZIA

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

EDSO urges sector-specific rules for smart meter data access

6 May 2022
Topic — The European Commission is consulting on rules to ensure fair data access and reuse.
Message — They want smart meters excluded from the product definition to avoid conflicting with energy sector rules. They propose making real-time data requirements optional because current infrastructure often cannot support them. They also seek to limit the definition of public sector bodies to prevent excessive data sharing.123
Why — This would shield operators from duplicative regulatory requirements and lower technical costs of data compliance.45
Impact — Public researchers and government bodies would face stricter limitations when attempting to access energy data.6
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

1 Mar 2022

The recast of the Energy Performance of Buildings Directive (EPBD) should serve to set the EU’s building stock on the road to deep renovation in line with the 2050 carbon neutrality goals. The building sector has great potential for improved energy savings, and regulations for new buildings already set stringent requirements for energy efficiency. E.DSO represents more than 350 million customers connected to 38 DSOs from all over Europe. Distribution System Operators are the key enablers of the energy transition fostering the integration of renewable energy sources, the deployment of energy efficient solutions and the empowerment of customers. The Directive is fully relevant to DSOs in view of their role for the integration of electric vehicles (EVs), Renewable Energy Sources (RES) and flexibility services and the deployment of smart grids. In general, we welcome the Commission's efforts to address the need to improve the energy performance of Europe's building stock. E.DSO raises the following concerns and proposes the following recommendations: • The recast must close the gap and market failure in managing energy needs of buildings. The EPBD should accelerate the decarbonization of buildings by reaping the benefits of energy efficiency and flexibility. It should advance consumer empowerment and the deployment of cost-efficient solutions. • The EPBD should better support switching to zero-emission and low-carbon energy solutions such as electricity-based appliances (e.g., electric heat pumps). They improve energy efficiency and reduce carbon emissions. Similarly, recharging infrastructure contributes to system integration (transport-energy) and carbon reduction targets. E.DSO’s feedback is tailored towards a forward-looking recast based on: • Decarbonisation of buildings through energy efficiency & flexibility. • Support of switching to zero-emission low-carbon energy solutions. • Acknowledgment of the benefits of connection to the public distribution grid for security and quality of supply and for system integration. • Recognition of the importance of smart meters for system integration and energy efficiency. Data provided by smart meters is a reliable source of information to increase energy savings through renovation. • Facilitated deployment of electricity smart technologies which empower consumers and increase the efficiency of the system. • The building of a holistic infrastructure for sustainable mobility which contributes to integration between the transport and energy sectors. • A robust framework for data exchange and interoperability supporting the integration of RES and flexibility services. A detailed account of E.DSO's feedback, including recommendations on specific provisions, can be found in the attached file.
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

25 Jan 2022 · Gas package proposal and the perspectives for renewable gas integration

Response to Review of Directive 2012/27/EU on energy efficiency

8 Nov 2021

E.DSO welcomes the revision of the EU’s approach to energy efficiency (EE) and the FF55 package as a tool to equip the EU’s economy for climate neutrality. However, we acknowledge that the role of DSOs is not sufficiently recognized in the EED or the FF55 despite their central role in the energy transition. The proposal entails important consequences for DSOs as it changes the rules for EE of distribution grids and provides a basis for the wider deployment of EE services. These services are predominantly connected to the distribution level making DSOs central to the debate on EE. E.DSO welcomes the new binding EE objective of at least -9 % in 2030 compared to the projections of the 2020 Reference Scenario (-36% on final energy and -39% on primary energy vs 2007 Reference Scenario for 2030). The introduction of the Energy Efficiency First Principle (EEFP) in planning, policy and major investment decisions is also very positive as it would lead to a reduction of CO2 emissions. Nevertheless, it seems the Commission approach to network operators does not rely on a holistic vision of EE and only emphasises network losses. E.DSO invites that a greater role is given to DSOs in the application of the EEFP and the deployment of EE solutions. This would be in line with the role of DSOs as ‘neutral market facilitators’ as recognised in the Electricity Market Regulation and their business model as naturally incentivised towards EE and system optimisation. DSOs are already committed to limit network losses when establishing network development plans and purchasing equipment (Ecodesign). Concerning Art 25, EE of DSO networks should be stimulated as part of an overall energy efficient system which goes beyond network losses. This approach would rely on energy system integration at local level and on smart grids as essential for higher EE. In this context DSOs would act as System Integration Facilitators contributing in multiple ways to EE including by facilitating EE in buildings and empowering customers to use smart meters to control energy consumption. For this reason, the focus should not be on network losses but on infrastructure investments which contribute to EE objectives by deploying cost-efficient solutions such as smart grids and services that integrate RES. The approach in Art 25 (2) to apply Cost Benefit Analyses, which account for wider system benefits, is more in line with this idea and would contribute to the adoption of such solutions. Specific comments: • Art 11 (2): DSO data can be used to facilitate energy audits. Energy consumption data can be used to evaluate ex-ante and ex-post the effectiveness of renovations. • The role of smart meters for EE is reduced in the context of electricity to providing customer information (Art 21 (2)) in comparison to a more prominent role of smart metering for gas and heating (Art 12 and 13). • The requirement to apply the EEFP in Art 25 (1) must not conflict the principle of cost-orientated tariffs in Art 18 (2) of Regulation 2019/943 and the Europe-wide trend towards kW-based (instead of kWh) tariffs in line with the idea that infrastructure costs are determined by grid load notwithstanding transported volume. In this regard, lower connection charges for cogeneration, as proposed in Art 25 (9), do not respect the principle of cost-reflection. • The second sentence of Art 25 (2) should clarify the possibility to maintain infrastructure that is not at the end of its life cycle in so far it supports efficient use of energy. • E.DSO suggests a review of the requirement in Art 27 (8) for MS to prevent, amongst others, DSOs from hindering the demand and delivery of EE services. This goes against the Electricity Market Regulation which recognises DSOs as neutral market facilitators which aim to facilitate such services. • Art 28: all measures, which aim to enhance efficient use of energy grids and system integration at grid level, should be explicitly recognised as contributing to EE.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

28 Oct 2021

E.DSO welcomes the revision of the EU’s approach to renewable energy (RE) and the FF55 package as a tool to equip the EU’s economy for climate neutrality. The proposal entails important consequences for DSOs which will have a central role in an integrated energy system with the customer at its centre. These consequences concern the integration of RES and the building and management of an integrated and decentralised energy system. E.DSO supports the raise of the 2030 RE target to 40% and the indicative target for penetration of RE in the final energy consumption of the building sector. This approach highlights the importance of electrification for the EU’s climate goals. We appreciate the recognition of electricity DSOs and their importance for the integration of renewable sources. Nevertheless, without a proper regulatory framework enabling investment by DSOs, an efficient decarbonization will not be feasible. While this position should be integral to the whole FF55 Package, the recast of the RED is especially well suited to include an obligation for MS or NRAs to (1) encourage investment facilitating RES integration and (2) to facilitate permitting procedures for new electricity lines while supporting the security and stability of the network. The disclosure of data under Art 1 (10) (1) should happen by means of existing infrastructure (e.g. smart meters) and not from new dedicated devices. Clarifications should be made on the process, the content of data sharing between DSOs and TSOs and the tools to make this data available. They must be kept to what is necessary for the purposes of interoperability and network operators must keep control of their data. This must be coherent with the corresponding Implementing Act under Art 24 of Directive 2019/944. Art 1 (10) (2) on bidirectional charging and transparency of storage is welcome as an important step towards unlocking flexibility. A next step should be to oblige service providers to offer smart charging and not to only prescribe charging installations to be ready for adaptation to smart charging. Similarly, Art 1 (10) (4) on non-discrimination contributes to unlocking flexibility and opens a real possibility to apply V2G. However, this is only feasible in a fully digitalised energy system: for this, smart meters, when deployed by MS, are an efficient tool. Art 1 (10) (3)’s requirement for non–publicly accessible power recharging points to support smart charging functionalities might imply extra costs for domestic consumers and prevent them from installing EV chargers. This provision should be mandatory for recharging points with more than 22 KW only. Smart charging for non-publicly accessible normal recharging points should therefore be encouraged on a voluntary basis as an opportunity for consumers to engage in flexibility services. Specific comments: • It is crucial to provide information about smart charging to national and local planning processes. It must be known as early and as exactly as possible where charging installations will be located. • Smart meters should be included in the definition of smart and bidirectional charging – a point of feedback relevant also for AFIR. • It should be clarified that heating and cooling flexibilities should be at the service of the network and should not represent a constraint for DSOs. • The provision of Art 1 (2) (c) on permitting procedures should be monitored within the reporting obligations in Art 1 (5) (d) so that the connection of new RES is not detrimental to the security and stability of the network. • Art 1 (4) (a) should accommodate DSO cross-border joint projects. The same approach should be reflected in the revision of the TEN-E. • Regarding the Impact Assessment, Part 1/2, 6.1.17, DSOs, while being neutral market facilitators, are also allowed to own, develop, manage or operate recharging points for electric vehicles subject to certain conditions and MS decision (Art 33 (3) of Directive 2019/944/EU).
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Response to Updating the EU Emissions Trading System

28 Oct 2021

E.DSO welcomes the revision of the EU’s approach to the Emissions Trading Scheme and the FF55 package as a tool to equip the EU’s economy for climate neutrality. However, we acknowledge also that the role of DSOs is not sufficiently recognized in the ETS revision or the FF55 despite their central role to the energy transition. E.DSO welcomes the amendment of Art 10d and the introduction of a requirement in paragraph (2) for 80% of the Modernisation Fund to be invested into, amongst others, the modernization of energy networks. However, we believe that the definition of energy networks should be expanded to include not only district heating networks, interconnections between MS and grids for electricity transmission, but also grids for electricity distribution. The reason for this is that electricity DSOs are at the forefront of the energy transition with 70 % of renewable sources as well as the majority of flexibility services connected to their networks. This requires a reinforcement of the capacity of distribution grids in a manner which would equip them to meet the climate-neutral objectives in the context of an integrated energy system. This approach would be consistent with the other legislative proposals of the FF55 package which rely heavily on distribution grids. Those include the Regulation on Alternative Fuels Infrastructure, where DSO networks will play a crucial role in the deployment of an EV charging infrastructure, and the Renewable Energy Directive, where DSOs are recognized as crucial for the integration of renewables and the energy system as a whole. Finally, the study, “Connecting the Dots” carried out by E.DSO and Deloitte suggests that in Europe DSOs only will need 375-425 bln EUR of investment in 2020-2030 in order to research, innovate and deploy new technologies to guarantee the safest and most reliable network for all customers. A copy of this study is attached to the feedback response.
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Response to Revision of Alternative Fuels Infrastructure Directive

28 Oct 2021

E.DSO welcomes the revision of the EU’s approach to Alternative Fuels Infrastructure and the FF55 package as a tool to equip the EU’s economy for climate neutrality. DSOs will be key actors for the achievement of the objectives of the regulation (AFIR) as the charging infrastructure for electric vehicles (EVs) as well as for other modes of transport will be connected to their distribution grids. E.DSO supports the introduction of mandatory MS targets for the deployment of EV charging infrastructure. We also support the introduction of targets for electric recharging infrastructure dedicated to light-duty and heavy-duty vehicles which will be connected at distribution level. We appreciate the methodology used to set those targets as well. E.DSO welcomes the role that the proposal attributes to electricity DSOs in the management of grid stability and flexibility, in the deployment of grid extensions and in reporting on bidirectional charging as an instrument for RES integration. In this regard, it should be considered that DSOs are allowed to own, develop, manage or operate recharging points for EVs subject to certain conditions and MS decision (Art 33 (3) of Directive 2019/944/EU). Specific comments: • The role of smart meters should be acknowledged in Art 2 and should be included in every definition of smart charging, bidirectional charging, and digitally connected recharging points as well as in technical specifications. This is important because in Recital 19 smart meters are mentioned in combination with smart charging thereby indicating that the Commission considers them as being different. • In Art 19 (6) and Annex II (2) DSOs must be associated to the definition of technical specifications on communication with the grid. Additionally, their right to access data from charging infrastructure should be confirmed. • Art 14 (3) confers large powers to NRAs in assessing the contribution of EVs to the flexibility of the energy system. This should be done coherently with the Clean Energy Package which already set a requirement for DSOs to conduct a periodical evaluation of flexibility needs in their own network development plans while consulting all interested parties. The control over flexibility evaluation should remain with DSOs without prejudice to the obligation for DSOs and TSOs to provide input to NRAs on the potential contribution of bidirectional charging to the penetration of renewable energy in the system (Art. 14(4)). • The proposal should pay greater attention on cybersecurity and power quality in the context of e-mobility. The proposal should explicitly prescribe open-source standards/protocols. An ambitious timeline is needed also for the adoption of standards and protocols such as for e-roaming and V2G with a clear demarcation of the role of network operators. While the proposal acknowledges the role of DSOs in the electrification of mobility and increases their responsibility, it does not account sufficiently for the need to reinforce their distribution grid to achieve the regulation’s objectives. This is despite the proposal’s Impact Assessment which states that “[DSOs] will have to invest into grid stability and flexibility and – where necessary - into grid extensions” (p. 108, part 1/2). This approach, to emphasize need for investment in grid connectivity and not in capacity, is upheld also in the Strategic rollout plan for the deployment of alternative fuels infrastructure. E.DSO invites the Commission to change its view on this matter as the study “Connecting the Dots” carried out by E.DSO and Deloitte suggests that in Europe DSOs only will need 375-425 bln EUR of investment in 2020-2030 in order to research, innovate and deploy new technologies to guarantee the safest and most reliable network for all customers. A copy of this study is attached to the feedback response.
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

30 Apr 2021 · To present and discuss the conclusions of the study of E.DSO and Eurelectric on the needs at distribution level with a 2030 time horizon, to ensure a timely, fair and cost-effective energy transition.

Meeting with Kadri Simson (Commissioner) and

26 Jun 2020 · Presentation of recommendations by EDSO on how DSOs could contribute to the EU recovery plan.

Response to Strategy for smart sector integration

5 Jun 2020

Summary The very goals the SSI Strategy rely on increasing electrification of all sectors and efficient cross-sector integration where fully electrified solutions are not possible. Therefore, smart grid infrastructure and related investments are needed. Moreover, the consumer perspective is important as it is paramount to achieve the Green Deal objectives. Accordingly, enhancing the consumers’ position, incl. the role of prosumers in optimised energy systems, is required, as well as the further development of the coordination and the interface between DSOs for electricity and gas. Therefore, DSOs must be assigned the role of “System Integration Facilitators”, as they are recognised as enablers of the energy transition and "Market Facilitators" as well. Most importantly, their roles must be clearly defined in the light of this strategy. The SSI Strategy should focus as well on: 1.Developing planning capacities and encourage acceptance through direct participation, 2.Use of renewable/decarbonised gases such as hydrogen or e-methane as part of the solution for an integrated energy system, in sectors that are hard to electrify, 3.Their role in the provision of long-term flexibility should be considered. Implementing circular economy principles, e.g. in a grid updating wave is required. Regarding energy markets, they can support the efficient transition towards integrated energy systems if the price signals are sufficient to ensure efficient decarbonisation.
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Meeting with Kadri Simson (Commissioner) and

28 Apr 2020 · Security of electricity supply and the role of DSOs in the context of the COVID-19 crisis, post-crisis economic recovery

Meeting with Kadri Simson (Commissioner) and

27 Jan 2020 · Decentralized energy systems, establishment of EU DSO entity

Meeting with Ditte Juul-Joergensen (Director-General Energy)

11 Oct 2019 · Introductory meeting. Energy policy priorities.

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

3 Apr 2019 · Set up a two-ways communication channel in the development of our climate change targets compliance project

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete), Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete) and

19 Jun 2018 · Clean energy package and role of DSOs

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

21 Feb 2018 · Smart grids

Meeting with Maroš Šefčovič (Vice-President) and

25 Apr 2017 · Energy storage

Meeting with Dominique Ristori (Director-General Energy)

24 Apr 2017 · Clean Energy for All Europeans package

Response to Commission Regulation establishing a guideline on electricity balancing

23 Dec 2016

Common response of CEDEC-EDSO-GEODE – part II Art 55 The ISP is set to 15min. In §2 TSOs within a synchronous area (SA) can jointly request for an exemption. To avoid the risk of having another ISP (than 15min) for all MS as an exemption within the Continental Europe SA it would be advisable to explicitly state that MS already at 15min do not change their ISP. For those MS which are using an ISP different from 15min the proposed text only provides a very short implementation period, which undermines the needed changes in metering-, IT-, and commercial infrastructures. A CBA on the harmonization of the ISP was published by Frontier Economics, which assessed the consequences of the harmonization at national and EU level for 4 different planning cases with each 2 different scenarios. From the results on national level, for the full harmonization scenario for 15min. based on unadjusted information provided by the participants in the CBA, we learn that the total cost significantly exceeds the total benefit in many MS from different control areas (such as Spain and Scandinavian countries). Therefore it is of utmost importance that the national regulatory authorities have a possibility to assess whether a longer implementation period would be needed in order to reduce costs and request for a deferred implementation at MS level. It may seem that the additional paragraph 2 of our proposal makes §3 obsolete, but §3 does not say that all TSOs in a synchronous area would ask for a global exemption, so the exemption could consist of asking a different ISP just for a number of MS in that synchronous area. Proposals: 5§4 Add new point (i) "the extension of the implementation period pursuant to article 55(1)." 55§1. By "seven" years after [...] periods. "Each regulatory authority may issue a reasoned decision for an extension of the implementation period in accordance with article 5(4). If the extension is longer than three years, the regulatory authority shall perform a cost-benefit analysis." New extra 55§2. "Members States applying an imbalance settlement period, at the moment of entry into force of this Regulation, of 15 min. will not change their imbalance settlement period, even if the exemption in paragraph 3 is granted." Remarks on several other articles: Art 5 DSOs worry about the timelines and the consistency of the proposed timings. It is important that there is enough time for the stakeholders to procure the needed IT-systems with sufficient public consultations and according to (national) legislation regarding procurement of these systems. Hence, instead of proposing a strict timing in the regulation, it could be more appropriate, for many of the requirements, that TSOs make a proposal for the implementation timeline and regulators approve it. Art 20 There are some concerns that the requirement for starting with EU platforms might be too ambitious and will lead to delays. A more practical approach might be advisable, the requirement in the regulation could require TSOs first to constitute a set of standard products and to ensure regional platforms (which to some extent already exist). Art 45 in combination with art 57 Art. 57§2(c) allows apparently for dual (asymmetric) pricing, meaning different prices depending on the imbalance direction. This paragraph seems to contradict the principle of financial neutrality of the TSO as described in art. 45§1(i). This contradiction could be avoided by deleting point c from art. 57§2.
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Meeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete)

10 Oct 2016 · Energy Efficiency

Meeting with Dominique Ristori (Director-General Energy)

14 Mar 2016 · Energy market design

Meeting with Miguel Arias Cañete (Commissioner) and BUSINESSEUROPE and

18 Feb 2016 · Market design

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Community of European Railway and Infrastructure Companies and

29 Sept 2015 · Metal Theft